-56- (B) Aggregation rules.-- (i) Special rule for leases of section 1245 property by partnerships or S corporations.--In the case of any partnership or S corporation, all activities with respect to section 1245 properties which-- (I) are leased or held for lease, and (II) are placed in service in any taxable year of the partnership or S corporation, shall be treated as a single activity. (ii) Other aggregation rules.--Rules similar to the rules of subparagraphs (B) and (C) of paragraph (3) shall apply for purposes of this paragraph. (3) Extension to other activities.-- (A) In general.--In the case of taxable years beginning after December 31, 1978, this section also applies to each activity-- (i) engaged in by the taxpayer in carrying on a trade or business or for the production of income, and (ii) which is not described in paragraph (1). (B) Aggregation of activities where taxpayer actively participates in management of trade or business.--Except as provided in subparagraph (C), for purposes of this section, activities described in subparagraph (A) which constitute a trade or business shall be treated as one activity if --Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
Last modified: May 25, 2011